“IT’S ALL ABOUT RELATIONSHIPS”
An interview with Jessica Janning, Regulatory Compliance Manager at CAPOL LLC
Image: Jessica Janning (left) and Klicia Boutala, forewoman in the fields for carnauba harvest (right)
Carnauba wax is a natural raw material that has been used as an ingredient in confectionery surface treatment for decades. The wax forms a natural protective layer on the leaves of the carnauba palm, which is harvested exclusively in the northeast region of Brazil. In September of 2022, our Regulatory Expert Jessica Janning traveled to Brazil to spend time with CAPOL’s suppliers of carnauba wax; getting to know the companies, the people and the processes. We talked to Jessica about her trip and her insights into CAPOL’s carnauba wax supply chain.
An interview with Jessica Janning, Regulatory Compliance Manager at CAPOL LLC
Image: Jessica Janning (left) and Klicia Boutala, forewoman in the fields for carnauba harvest (right)
Well, I was initially asked to accompany a US customer on an audit – the customer wanted to understand the labor standards within our carnauba wax supply chain. We’ve always worked with carnauba wax suppliers whom we felt were doing constant due diligence when it came to ethics in supply chain. In fact, we never had any reason to doubt the standards and practices until a renowned international confectionary manufacturer was called upon to examine their own supply chain in 2017. It was a real eye-opener for us because it revealed potentially labor standard issues across the carnauba harvesting and processing supply chain in Brazil. CAPOL went into immediate action, having two colleagues travel to the region and participate in the investigations and work with our suppliers to fully understand the breadth of the situation and work collaboratively in its remedy. At this time we also joined along with our suppliers the IRC, Initiative for Responsible Carnauba, as a founding member. This ultimately led to establish a deeper and more personal connection with our suppliers. During the pandemic we had to suspend regular visits, but this fall we were back in the saddle again, and it felt great.
As the food industry strives to create more transparency for consumers, we as a supplier to finished goods manufacturers have a greater responsibility to provide more detailed and fully vetted information about CAPOL’s supply chain. Most of our raw materials are sourced from nature. This has resulted in evolving partnerships with our suppliers as we look to understand the scope and source of the raw materials, all the way down to farm and field level.
The farms are piecemeal and spread all over the place, unlike, sunflower or wheat fields for example. There are pockets of carnauba palm trees in the wild. In this sense, it is a real challenge to track the entire supply chain down to the individual worker and tree. You have groups of workers or farmers harvesting the carnauba palms in the wild and selling them as needed to various producers. This can lead to a very disjointed supply chain with no checks and balances when it comes to safety and/or fair wages. In the past, this labor model although problematic in some cases was also the only source of income and livelihood for many people within this region. The workers having somewhat of a nomadic life during harvest season, sleeping in hammocks and working off the land and making money where they could sell their wares and yields.
We felt that if we could get more involved and contribute in a constructive way in this area, then we wanted to do it. As these efforts grew, the relationships with the suppliers have grown deeper, too. The food industry has established frameworks for handling non-conformities within the various audit schemes, like BRC or FSSC22000. Companies are responsible for providing detailed information about infractions. If/when an issue arises, you work closely with your supplier as to what corrective actions can be taken to rectify the issue. It’s not about suspending a supplier for an infraction, it’s about supporting them in achieving the necessary standards through remedial measures. That being said, we were lucky that our suppliers had many of the recommended guidelines and standards already in place through their own corporate programs. In fact, both our suppliers have gone for every certification possible over the past few years – organic seals, ethical standards down to the farm, responsible carnauba, you name it.
I had a chance to spend time with both of our suppliers, both are family run businesses with a ton of passion for their family business and the carnauba industry overall. They reported how their business and the industry had changed over recent years. I was able to walk the production facilities, meeting production workers, lab technicians, and office personnel handling our day to day orders. We discussed health and safety, various certifications and the ethical business practices at play within their business. It was beautiful to see their dedication to the communities from which they’re procuring the raw materials.
I was representing CAPOL as one of our customers carried out a Workplace Conditions Assessment (WCA) at one of our suppliers. The WCA audit focuses on more than just the production facility – it also focuses on the harvest and raw material procurement in the field. It covers business practices from an ethical standpoint: worker’s wages, conditions, safety measures, ergonomics, training programs, certifications, financing, accounting, taxes, etc.
On the first day we went to the fields and got a full rundown of the workers’ days. The labor force is contracted throughout harvest season. The labor standards require that the workers wear full gear, protective jumpsuits, boots, gloves, hats, masks, shield guards. Before these standards were established, the work was typically done in tank tops and flip-flops because of the heat. Workers were not excited about having to wear the Personal Protective Equipment (PPE), but they’ve grown to understand that it’s necessary for their own safety.
Everything was done so well. You could argue that since it was an audit, everyone was prepared, but I don’t think that was the case. I have to give these women credit. I’ve done enough audits to see that this was just a typical day of work.
We ran through the whole production process, so they’re cutting and hauling the harvested carnauba leaves from the field, to the drying fields, and then through the chopper. Each step of the way, workers wear protective gear and use best practices and Good Manufacturing Processes (GMPs). The wax is derived from the powder that acts as protective coating to the palm leaves and plant. Once the leaves are fully dry, they are chopped and the powder is isolated, collected and then processed through various proprietary methods depending on the desired end use. It is a very labor intensive process.
At the processing facilities, there were several ergonomic assessments as it is a multistep process which is quite labor intensive; i.e. lifting and sorting bags and transporting material. But it’s also highly automated, so you have a lot of people pushing buttons. It’s much easier to supervise labor standards in this area. The next day, we checked records for a full day. The auditors would say, “I need to see this document,” and the document was provided. Finally, employees were interviewed to ensure that they were treated correctly, paid on time, etc.
They passed the audit with flying colors. To me, that was genuine validation that they’re doing their due diligence. Next year, we’ll be doing a WCA audit with our other supplier. We visited them this time, too, but we did not do the a complete audit or visit their fields.
The initiative is committed to ensuring responsible production with respect to human rights and international labor conventions as well as biodiversity in the carnauba extraction regions. It’s the commitment that we’ll do right by our customers and the supply chain in which we’re procuring. It’s made up of a network of Brazilian and international actors in the Carnauba wax production industry, government and civil society institutions, all supported by the German Society for International Cooperation (GIZ). Collaborating with as many stakeholders as possible on this is important. We as a company only purchase a small proportion of the carnauba wax that is produced. Which is why the industry needs to join forces to drive changes for the better together.
And we play an active role by going down there, ensuring that our due diligence is done and that our supply chain is vetted and verified. And since every community is different, it is about understanding where and how they’re working and making sure that the people are validated and appreciated. At the end of the day, it’s all about relationships. And our relationships with them are growing stronger. That’s the goal – to make the people we’re procuring from accountable to their workforce and the environment in which they are sourcing the raw material from.
The Brazilian people and culture are very warm and lovely. Once I left, I was already looking forward to going back to Brazil. It’s really an inspiring place. Since we use a lot of natural and wild raw materials, CAPOL has a responsibility to really get in there and participate making these programs better, especially in support of the indefatigable workforce. They, too, have kids to feed and a life to live. It’s a very tangled web and while we’ve made great progress in the area of carnauba wax, we’re aware that, when it comes to other raw materials, the situation is similarly complex – and there’s still a lot of work to be done. It’s not necessarily a straightforward or simple task. But we’re on it. And it makes me really happy that at CAPOL we’re walking the talk. I’m proud of our company.
